Recently, NCCS submitted comments to the Center for Medicare and Medicaid Innovation on its proposed Oncology Care Model (OCM), an episode-based payment model that emphasizes care planning and coordination and cancer care system transformation. The OCM represents an important step forward in encouraging patient-centered cancer care, and NCCS commended CMMI for its efforts. We are pleased that the model identifies five specific activities that practices must undertake in order to participate in OCM, and we believe that these activities will drive the cancer care transformation process to improve overall quality of care.
NCCS especially commends the decision to require that the cancer care plan in the OCM contain the 13 components that were identified by the Institute of Medicine as care management plan elements in its report, “Delivering High-Quality Cancer Care: Charting a New Course for a System in Crisis.” Over the course of long involvement in efforts to encourage cancer care planning, NCCS has determined that the cancer care plan must be comprehensive in order to foster shared decision-making, appropriate symptom management, and care coordination. We also maintain that the development of strong and specific cancer care plans will trigger practice transformation and encourage appropriate utilization of health care resources.
In addition, we recommended some refinements in the OCM, identified issues to be addressed, and proposed that the per-beneficiary-per-month payment for enhanced services be set at a fairly aggressive level to support the practice transformation required and to encourage provider participation. We also suggested structuring the PBPM as an incentive system, with higher payments as providers demonstrate that they have achieved the practice transformation outlined in the OCM.